Summary
The document discusses the issue of “Combined Exposure” to unintentional mixtures of chemicals in various environments such as drinking water, food, and air. Current risk assessments typically evaluate chemicals individually, but real-life scenarios involve simultaneous exposure to multiple chemicals. The paper identifies the challenge of managing these combined exposures without resorting to disproportionate actions. Cefic proposes a stepwise approach to address these risks, focusing on defining terms, setting priorities, and ensuring consistent EU legislation. The paper opposes the use of a generic Mixture Assessment Factor (MAF) under REACH, arguing it is overly simplistic and not scientifically sound.
Key Takeaways
- Effective Framework: Develop a robust, evidence-based framework targeting specific chemicals and exposure patterns that pose real, demonstrated risks from combined exposures.
- Stepwise Approach: Propose a phased and proportionate approach starting with clear definitions and identifying priority exposure scenarios, ensuring regulatory measures are only applied where necessary.
- Rejection of MAF: Oppose the introduction of a generic Mixture Assessment Factor under REACH, citing its lack of scientific backing and potential for inconsistent regulation.